Reverse charge and latest issues

Reverse Charge and Latest Issues in
Service Tax
Advocate Forum
November 8, 2014
Presented by:
CA Gaurav Gupta
FCA, LLB, DISA
Partner
MGS & Co.

Reverse Charge
• First sought to be introduced in 1997 for GTA and clearing Agents
• Finance Act, 1994 was not amended to provide for liability of payment service recipient and
amendment was primarily sought by amending Rules
• Held as ultravires the Act by Apex Court in Laghu Udyog Bharati (2006) (2) STR 276 (SC)
• Reintroduced by amendments in charging section vide amendments in 2000 and 2003
• This time upheld by Apex Court in Gujarat Ambuja Cement Ltd. 2006 (3) STR 608 (SC).
• Validity of the collection of service tax from service receiver was upheld in the case of All
India Tax Payers Welfare vs Union Of India [(2006) 205 CTR Mad 360, 2006 4 STR 14]
Reverse Charge & Latest issues CA Gaurav Gupta 3

Reverse Charge
• Section 68 provides for mechanism for collection of Service Tax
• Section 68(2) of the Finance Act, 1994 provides for the person other than service provider
for payment of service tax.
• Section 68(2) of the Finance Act, 1994 provides that Government may notify any service
with respect to which the liability of to pay service tax may lay upon the service recipient as
a person liable to pay service tax.
• Rule 2(1)(d) of Service Tax Rules, 2004 also amended suitably as it defines “person liable
to pay Service Tax”

Reverse Charge
Prior to July 1, 2014
Reverse charge liability was existing on following four category of services
• GTA
• Sponsorship Services
• Insurance Services
• Import of Services
Post July 1, 2014
• Reverse charge liability effected on 11 cases vide Notification No. 30/2012-ST, dated June
20, 2012
• Enlarged Scope

Reverse Charge
Description of
Service
Service Provider Service Recipient Liability of provider Liability of recipient
Insuance Insurance Agent Person carrying on insurance business NIL 100%
Sponsorship Any person Body Corporate or partnership firm
located in taxable territory
Nil 100%
GTA Goods Transport
Agency
Six Specified persons Nil 100%
Arbitral Tribunal Arbitral Tribunal To any business entity located in
taxable territory
Nil 100%
Legal Services Individual
Advocate or a firm
of advocates
Business entity located in taxable
territory
Nil 100%
Rent a Cab
(claiming
Abatement )
Specified persons To any business entity registered as
body corporate located in the taxable
territory
Nil 100%

Reverse Charge
Description of
Service
Service Provider Service Recipient Liability of provider Liability of recipient
Rent a Cab (not
claiming
Abatement )
territory
50% 50%
Manpower
supply including
Security
territory
25% 75%
Works Contract Specified persons To any business entity registered as
territory
50% 50%
Directors Individuals / body
corporate
To any business entity registered as
territory
Nil 100%
Services by non
resident
By any person
who is located in
non-taxable
territory
Any person located in taxable
territory
Nil 100%
Support Service Govt.
or Local Authority
Business Entity Nil 100%

• Invoice:
- Service tax relating to provider’s share shall be charged on invoice
- Service tax relating to service receiver’s share may be mentioned on invoice
with the mention that he is required to pay the balance amount.
• Cenvat of joint charge mechanism input services:
- Cenvat Credit of Provider’s share of Service tax can be availed on the basis of
invoice
- Cenvat Credit of Recipient's share of services can be availed on the basis of
challan
- Cenvat Credit in case of full reverse charge payment can be taken on the basis
of Challan and payment to vendor is no longer a condition
- Cenvat Credit in case of reverse charge payment can be taken only when
payment to vendor is made eevn when challan is paid for partial liability by
recipient of services
Reverse Charge

Reverse Charge
Certain points of specific Mention
• Service Tax payable under reverse charge even on advance for services
• Service recipient is required to get himself registered and file returns
• Interest and penal provisions in case of delay applicable even under reverse charge

Reverse Charge
Circular No. 162/13 /2012 –ST Dt. 6-7-2012
It is clarified that the provisions of partial reverse charge would also be applicable in
respect of such services where point of taxation is on or after 01.07.2012 under the
applicable rule in respect of the service provider.

Rule 7 of Point of Taxation Rules, 2011.
As per Rule 7 of POT rules the point of taxation in case of reverse charge mechanism shall
be the date on which payment is made by the service receiver to the service provider.
Therefore liability to pay service charge is the month in which payment to service provider is
made.
However if payment to the service provider is not made within Three months from the date of
invoice than point of taxation shall be determined as first day after three months.
Exception is that when service provider is outside India is Associated Enterprise, the service
receiver is liable to pay service tax as soon as the account of service provider is credited in
books of account of service receiver.
Reverse Charge

Reverse Charge
Certain important questions
Ques 1: What does a service provider need to indicate on the invoice when he is liable to pay
only a part of the liability under the partial reverse charge mechanism?
Ques 2: If the service provider is exempted being a SSI (turnover less than
Rs. 10 lakhs), will service recipient still be liable to deposit under reverse charge?
Ques 3: Does an SSI unit (having turnover less than 10 Lakhs) liable to deposit Service tax
under reverse charge?
Ques 4: How will service recipient avail Cenvat Credit?

Reverse Charge
Certain important questions
Ques 5: Do I need separate registration to discharge my liability under reverse charge?
Ques 6: Do I need to pay interest on late payment of liability under reverse charge?
Ques 7: Can I pay reverse charge liability by Cenvat Credit?
Ques 8: X Ltd. engages a contractor Mr C to construct his factory. Both parties agreed that
Contractor C would charge the entire service tax and discharge the liability. Whether X is
liable to pay liability under reverse charge?

Reverse Charge
Certain points of specific Mention - GTA
• Specified Persons:
o Any factory registered under or governed by the Factories Act, 1948 (63 of 1948)
o Any society registered under the Societies Registration Act, 1860 (21 of 1860) or under any other
law for the time being in force in any part of India
o Any co-operative society established by or under any law
o Any dealer of excisable goods, who is registered under the Central Excise Act, 1944 (1 of 1944) or
the rules made there under
o Any body corporate established, by or under any law
o Any partnership firm whether registered or not under any law including association of persons
• Exemption as available for transportation through GTA for specified goods available to
recipient also
• Exemption for INR 750/1500 charge available to recipient also

Reverse Charge
Certain points of specific Mention – Rent a cab / Manpower supply / Works contract
Specified Persons (Provider):
• Any individual
• Hindu Undivided Family
• partnership firm, whether registered or not, including
• association of persons
located in the taxable territory
Points to note:
• Proprietorship firm included

Reverse Charge
Recipient:
• To any business entity registered as body corporate located in the taxable territory
Business Entity – 65B(17) - "business entity" means any person ordinarily carrying out any
activity relating to industry, commerce or any other business or profession
Body Corporate – Section 2(7) of Companies Act – includes company incorporated in India
but does not include –
(a) Corporation Sole,
(b) Registered Cooperative Society
(c) Any other body corporate as notified by Central Government

Reverse Charge
Body Corporate:
Characteristics:
- Incorporated under some law
- Perpetual succession
- Ability to hold property in own name
Examples:
- Companies (whether incorporated in India / outside India), LLPs,
- Corporations under laws
Not body Corporate:
- Proprietorship Concern
- HUF
- Society under Societies Act
- Partnership firms

Whether recipient
PSUs
Yes
Charitable Trusts No, not business entity
Partnership firm No, not body corporate
HUF No, not a body corporate
Reverse Charge

Reverse Charge
Certain points of specific Mention – Rent a cab
• Persons in same line of business, no liability under reverse charge mechanism
• Radio taxi not included
Certain points of specific Mention – Manpower Supply
• Recruitment agencies not covered
• To include all amounts including ESI/ PF etc. while determining liability under reverse
charge as well

Reverse Charge
Case 1:
Mr. X engages a contractor Mr C to construct his factory. As per contract all material to be
provided by Mr A. Mr. C shall provide 10 labour for the execution of the contract @Rs 600
per man day. Overtime shall be charged extra @ Rs 100 per hour. The persons employed at
construction work are working under the superintendence and control of the Contractor Mr. C.
Whether this transaction is covered under manpower supply service or works contract?
Answer:
None,
a. Its not manpower supply because both superintendence and control over the labour lies
with Mr. C
b. Its not a works contract because no property in goods is transferred from Mr C to Mr A.

Reverse Charge
Certain points of specific Mention – Works Contract
• Works Contract Service means a contract wherein:
o †VAT is applicable on transfer of property in goods used in such Works contract
o †such contract is for the purpose of carrying out construction, erection, commissioning,
installation, completion, fitting out, repair, maintenance, renovation, alteration
o †of any moveable or immovable property
• Ratio of provider and recipient are independent

Effective rate
Original Works viz.,
new Constructions,
installation of new
machinery
Valuation – 40%
Effective Rate –
2.4724%
Other Contracts, including
finishing services of an
immovable proeprty
Valuation – 70%
Effective Rate – 4.371%
Reverse Charge
Rule 2A : Option – II
– October 1 , 2014 onwards
Certain points of specific Mention – Works Contract

Reverse Charge
Certain points of specific Mention – Non resident
• Exemption to Government, charitable trusts (Specific), Individuals for non business purpose
and RBI for forex management.
• Payment to service provider in J&K covered under reverse charge liability
Certain points of specific Mention – Manpower Supply
• Recruitment agencies not covered
• To include all amounts including ESI/ PF etc. while determining liability under reverse
charge as well

Reverse Charge
Failure to pay Service Tax under
All Implications as is in case of Service provider being person liable to pay.
Hindustan Coca Cola Beverages P. Ltd. v. CIT, 293 ITR 226 (SC) :
“The Tribunal, upon rehearing the appeal, held that though the appellant-assessee was rightly
held to be an ‘assessee in default’, there could be no recovery of the tax alleged to be in
default once again from the appellant, considering that Pradeep Oil Corporation had already
paid taxes on the amount received from the appellant. It is required to note that the
Department conceded before the Tribunal that the recovery could not once again be made
from the tax deductor, where the payee included the income on which tax was alleged to
have been short deducted in its taxable income and paid taxes thereon. There is no dispute
whatsoever that Pradeep Oil Corporation had already paid the taxes due on its income
received from the appellant and had received refund from the Tax Department. The Tribunal
came to the right conclusion that the tax once again could not be recovered from the
appellant (deductor-assessee), since the tax has already been paid by the recipient of
income.” CA Gaurav Gupta 24

Latest Issues
Restructuring of Service Tax Commissionerate
CBEC has ordered restructuring of its existing organizational set up with certain major
changes particularly in terms of introduction of more Commissionerates. The said
restructuring would be effective from October 15, 2014.
CA Gaurav Gupta 26
S.no. Officers Jurisdiction
1 Chief Commissioner of
Service Tax, Delhi
(i) Principal Commissioner of Service Tax -I, Delhi
(ii) Principal Commissioner of Service Tax -II, Delhi
(iii) Commissioner of Service Tax -III, Delhi
(iv) Commissioner of Service Tax -IV, Delhi

Latest Issues
CA Gaurav Gupta 27
2 Principal Commissioner of
Service Tax -I, Delhi
Districts of New Delhi, Central Delhi, East Delhi, North-East
Delhi, North Delhi and Shahdara in National Capital Territory
of Delhi.
3 Principal Commissioner of
Service Tax -II, Delhi
Districts of South Delhi and South-East Delhi in National
Capital Territory of Delhi.
4 Commissioner of Service
Tax -III, Delhi
Districts of North West, South West and West Delhi in
National Capital Territory of Delhi.
5
Commissioner of Service
Tax -IV, Delhi
Districts of Gurgaon, Rewari, Mewat and Mahendragarh in
the State of Haryana.

Latest Issues
CA Gaurav Gupta 28
7
Commissioner of Central
Excise (Audit)-I, Delhi
Commissioner of Central
Excise (Audit)-II, Delhi
(i) Principal Commissioner of Service Tax -I, Delhi
(ii) Principal Commissioner of Service Tax -II, Delhi
(iii) Commissioner of Service Tax -III, Delhi
(iv) Commissioner of Service Tax -IV, Delhi
8
Commissioner, Large
Taxpayer Unit, Delhi The whole of India

Latest Issues
Clarification on services of Joint Ventures (“JVs”) to its members or vice versa
Vide Circular No. 179/5/2014-Service Tax dated September 24, 2014, CBEC has clarified the
levy of Service Tax on taxable services provided (i) by the members of the Joint Venture (JV)
to the JV and vice versa; and (ii) inter se between the members of the JV, as under:
- cash calls are capital contributions made by the members of JV to the JV and would not
be taxable if are merely a transaction in money. If such cash calls are associated with
any service (for eg. Advance for services or provision of cash calls in lieu of some rights
etc.), then such amounts would be taxable under Service Tax.
- Payments towards taxable services received from a member or a third party is in the
nature of consideration and hence attracts service tax.
- Payment to a member for provision of services of management of cash calls would be
taxable as provided by member to JV.
- Similarly any support service by a member would be taxable under Service Tax.
CA Gaurav Gupta 29

Latest Issues
Clarification on predeposit to be made in case of appeals
Vide Circular No. CIRCULAR NO. 984/08/2014-CX, dated September 16, 2014, CBEC has
clarified many points in relation to the amended Section 35F requiring predeposit before
submission of an appeal before first and second appellate authorities. Such clarifications are
as under:
- The amended provisions apply to appeals filed after 6th August, 2014.
- Interest to be paid at the rate of 6% in cases where such pre-deposit is made and later
required to be refunded to assessee. However, no interest shall be paid on predeposit
made in excess of amount required as pre deposit
- In case of demand and penalty, in the event of appeal against the order of Commissioner
(Appeal) before the Tribunal, 10% is to be paid on the amount of duty demanded or
penalty imposed by the Commissioner (Appeal). It is clarified that since ‘or’ has been
used, 10% of either amount is to be deposited and duty shall get preference over penalty
for predeposit. CA Gaurav Gupta 30

Latest Issues
- In a case, where penalty alone is in dispute and penalties have been imposed under
different provisions of the Act, the pre-deposit would be calculated based on the
aggregate of all penalties imposed in the order against which appeal is proposed to be
filed.
- Payment made during the course of investigation or audit, prior to the date on which
appeal is filed, to the extent of 7.5% or 10%, subject to the limit of Rs 10 crores, can be
considered to be deposit made towards fulfillment of stipulation under Section 35F of the
Central Excise Act, 1944
- Date of filing of appeal shall be deemed to be the date of deposit and interest on refund
shall be applicable from such date only
- In case of short payment, appeal can be rejected.
CA Gaurav Gupta 31

Latest Issues
- No coercive measures for the recovery of balance amount i.e., the amount in excess of
7.5% or 10% deposited in terms of Section 35F of Central Excise Act, 1944 or Section
129E of Customs Act, 1962, shall be taken during the pendency of appeal where the
party/assessee shows to the jurisdictional authorities:
(i) proof of payment of stipulated amount as pre-deposit of 7.5%/10%, subject to a
limit of Rs.10 crores, as the case may be; and
(ii) the copy of appeal memo filed with the appellate authority.
- Demand recoveries can be made in between date of order and deposit of appeal to next
forum with requisite redeposit
- If the Department contemplates appeal against the order of the Commissioner (A) or the
order of CESTAT, which is in favour of the appellant, refund along with interest would still
be payable unless such order is stayed by a competent Appellate Authority
CA Gaurav Gupta 32

Latest Issues
- It is clarified that refund of pre-deposit made should not be withheld on the ground that
Department is proposing to file an appeal or has filed an appeal against the order granting
relief to the party
- Challan to be presented along with appeal and details thereof to be provided in column 6
of ST-4 or other applicable columns in case of CESTAT.
- No special format for refund application of predeposit amount. A simple letter from the
person who has made such deposit, requesting for return of the said amount, along with a
self attested Xerox copy of the order in appeal or the CESTAT order consequent to which
the deposit becomes returnable and attested Xerox copy of the document evidencing
payment of such deposit, addressed to Jurisdictional Assistant/Deputy Commissioner of
Central Excise and Service Tax or the Assistant/Deputy Commissioner of Customs, as the
case may be, would suffice for refund of the amount deposited along with interest at the
rate specified. CA Gaurav Gupta 33

Latest Issues
Radio Taxi Made Taxable
- Radio tax deleted from negative list w.e.f. October 1, 2014 and thus, is now taxable
- ““radio taxi” means a taxi including a radio cab, by whatever name called, which is in two-
way radio communication with a central control office and is enabled for tracking using
Global Positioning System (GPS) or General Packet Radio Service (GPRS)”
All sale of space except print media made taxable:
- Service tax leviable currently on sale of space or time for advertisements in broadcast
media, namely radio or television [section 66D (g) read with section 66B]
- This category has been amended w.e.f. October 1, 2014 to include all except print media.
- The new levy would further extend to advertisements in internet websites, out-of-home
media, on film screen in theatres, bill boards, conveyances, buildings, cell phones,
Automated Teller Machines, tickets, commercial publications, aerial advertising, etc.
CA Gaurav Gupta 34

Latest Issues
Radio Taxi Made Taxable
- Radio tax deleted from negative list w.e.f. October 1, 2014 and thus, is now taxable
- ““radio taxi” means a taxi including a radio cab, by whatever name called, which is in two-
way radio communication with a central control office and is enabled for tracking using
Global Positioning System (GPS) or General Packet Radio Service (GPRS)”
All sale of space except print media made taxable:
- Service tax leviable currently on sale of space or time for advertisements in broadcast
media, namely radio or television [section 66D (g) read with section 66B]
- This category has been amended w.e.f. October 1, 2014 to include all except print media.
- The new levy would further extend to advertisements in internet websites, out-of-home
media, on film screen in theatres, bill boards, conveyances, buildings, cell phones,
Automated Teller Machines, tickets, commercial publications, aerial advertising, etc.
CA Gaurav Gupta 35

Latest Issues
Changes in Abatement Notificaiton
- Allowance of Cenvat credit of another rent a cab operator in case of availment of Cenvat
Credit by rent a cab operator
- Tour operator service providers are also being allowed to avail CENVAT credit on the
input service of another tour operator, which are used for providing the taxable service.
This is being provided to avoid cascading of taxes.
- Taxable portion in respect of transport of goods by vessel is being reduced from 50% to
40%. Effective service tax will decrease from the present 6.18% to 4.944%, with effect
from 1st October, 2014.
CA Gaurav Gupta 36

Latest Issues
Changes in Determination of Rate of Exchange
- Earlier determined by Customs Rate as notified from time to time
- vide Notification 19/2014-Service Tax, Dated: August 25, 2014, Service Tax Rules, 1994
have been amended to incorporate the following rules:
“11. Determination of rate of exchange.– The rate of exchange for determination of
value of taxable service shall be the applicable rate of exchange as per the generally
accepted accounting principles on the date when point of taxation arises in terms of the
Point of Taxation Rules, 2011.
12. Power to issue supplementary instructions.– The Board or the Chief
Commissioners of Central Excise may issue instructions for any incidental or
supplemental matters for the implementation of the provisions of the Act.”
- AS 11- For practical reasons, a rate that approximates the actual rate at the date of the
transaction is often used, even average rate can be used. However, if exchange rates
fluctuate significantly, the use of the average rate for a period is unreliable
CA Gaurav Gupta 37

Latest Issues
Changes in Reverse Charge
- In renting of motor vehicle, where the service provider does not take abatement the
portion of service tax payable by the service provider and service receiver will be modified
as 50% each.
Interest provision made harsh
- Simple interest rates per annum payable on delayed payments under section 75, are
prescribed as follows:
CA Gaurav Gupta 38
Sl.No Period of delay Rate of simple interest
1. Up to six months 18 per cent.
2. More than six months
and up to one year
18 per cent. for the first six months of delay and 24 per cent. for the delay beyond six months.
3. More than one year 18 per cent. for the first six months of delay; 24 per cent. for the period beyond six months up to
one year and 30 per cent. for any delay beyond one year.

Latest Issues
Mandatory E Payment
- E-payment of service tax is being made mandatory for all assesses. Relaxation from e-
payment may be allowed by the Deputy Commissioner/Asst. Commissioner on case to
case basis.
Change of place of provision in case of intermediary of goods:
- The definition of intermediary is being amended to include the intermediary of goods in its
scope. Accordingly, an intermediary of goods, such as a commission agent or
consignment agent shall be covered under rule 9(c) of the Place of Supply of Services
Rules and his place of provision shall be the location of service provider. Accordingly, all
commissions for foreign buyers / sellers shall now be taxable in India and vice versa.
- Thus, there shall be no longer an export of service by Commission agent.
CA Gaurav Gupta 39

Latest Issues
Change of point of taxation in case of reverse charge mechanism
- The first Proviso to rule 7 of the Point of Taxation Rules is being amended to reduce the
time allowed for payment to service provider from six months to three months.
- Suitable provision for invoices issued before October 1, 2014 and whose payment period
of six months is pending as on October 1, 2014 is made by way of Rule 10 which
provides that if payment is made within six months from the date of invoice, date of
payment shall be point of taxation, else Rule 3 shall apply.
CA Gaurav Gupta 40
Date of payment Point of taxation
Payment made to vendor within three months
from date of invoice
Date of Payment
Payment made to vendor after three months
from date of invoice
First day that occurs immediately after a period
of three months from the date of invoice

Latest Issues
Ratio of services in Works contract modified
- In Rule 2A of the Service Tax (Determination of Value) Rules, 2006, category “B” and “C‟ of works
contracts are proposed to be merged into one single category, with percentage of service portion as
70%. Thus, the following two categories of valuation under Option 2 of Rule 2A shall remain in case of
works contract:
CA Gaurav Gupta 41

Latest Issues
Date of Service Tax return extended
- Central Board of Excise & Customs has extended the date of submission of Service Tax
return for the period from 1st April 2014 to 30th September 2014, from 25th October,
2014 to 14th November, 2014 vide Order No.2/2014.
CA Gaurav Gupta 42

Latest Cases
Interest cannot be demanded beyond one year if extended period cannot be evoked
Jai Bharat Maruti Ltd. v CCE [2014] 50 taxmann.com 224 (Punjab & Haryana)
Reliance placed on CCE v. VAE VKN Industries (P.) Ltd. [2014] 44 GST 171/42 taxmann.com
565, wherein it was held that:
"6. There is no dispute that assessee has paid the differential duty on supplementary
invoices regularly and has shown the same in the ER-I returns, which were filed
regularly before the department, therefore, issuance of show cause notice for interest on
the delayed payment should also be within a period of one year as stipulated under
Section 11-A of the Act. Therefore, department has absolutely no jurisdiction to issue
show cause notice after expiry of the period of limitation for interest on the delayed
payment for the period from 2002-03 to 2005-06.”
CA Gaurav Gupta 44

Latest Cases
Service Tax cannot be levied on value on which VAT is paid - J.P. Transformers [2014]
50 taxmann.com 31 (Allahabad)
• The assessee was paying service tax on labour charges but did not pay service tax on
consumables and items used in repair of transformers on ground that excise duty/VAT was
paid thereon. Revenue argued being consumables, they were not goods used in contract.
• Hon’ble Court upheld the decision of Tribunal holding that no Service Tax can be levied
when the agreements and invoices reflected the cost of materials and labour separately, and
that the assessee had duly paid VAT/CST and excise duty on the goods sold, is not in
dispute.
• Similarly, in the case of CCE v Mahendra Engineering Ltd. [[2014] 49 taxmann.com 379
(Allahabad)], Hon’ble Allahabad High Court has held the value of consumables when
charged seeprately and when VAT is paid on such value shall not form part of value of taxable
services for levy of Service Tax.
CA Gaurav Gupta 45

Latest Cases
Service Tax cannot be charged on reimbursement
Intercontinental Consultants
• Assessee company was providing consulting engineering services but did not pay service
tax on reimbursements towards expenses incurred by it such as air travel, hotel stay, etc.
• Department sought inclusion thereof in value under rule 5(1) ibid. It was held that rule 5(1)
providing for inclusion of value of expenditure or costs incurred by service provider had
travelled beyond scope of section 67 and was ultra vires
• Appeal against the above decision by revenue was admitted in Supreme Court [2014] 49
taxmann.com 520 (SC)
CA Gaurav Gupta 46

Latest Cases
Service Tax demand arising consequent to retro-amendments would invite interest
and not penalty
Commissioner of Central Excise, Puducherry Commissionerate v. CESTAT [2014] 50
taxmann.com 74 (Madras)
• It was held that where demand of Service Tax has been validated by way of series of
retrospective amendments, issue of notice for recovery and demand of interest was valid but
penalty could not be levied.
CA Gaurav Gupta 47

Disclaimer
This presentation has been prepared for internal use of
ICAI and its members. The contents of this document are
solely for informational purpose. It does not constitute
professional advice or a formal recommendation. The
presentation is made with utmost professional caution but
in no manner guarantees the content for use by any
person. It is suggested to go through original statute /
notification / circular / pronouncements before relying on
the matter given. The presentation is meant for general
guidance and no responsibility for loss arising to any
person acting or refraining from acting as a result of any
material contained in this presentation will be accepted by
us. Professional advice recommended to be sought
before any action or refrainment.
CA Gaurav Gupta
Partner
MGS & Co.
507 B, D-Mall, Netaji Subhash Palace,
Delhi - 110034
+91 11 32962487
+91 11 2735 2487
+91 98110 13940
cagauravmgs@gmail.com
Thank you

Reverse charge and latest issues

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